TO:

FAX NO:

ATTN:

^T)2*‘d !/J. ll

&/3J SSI

FROM: jnFAX NO: (309)672-2726

4349 Southport Road * Peoria, IL 61615 P.O. Bax 9071 • Peoria, IL 61612-9071

(309) 676-4B93

?M 1MH

DATE: 10. /#’/

TOTAL PAGES INCLUDING

COVER PAGE; /g

CONTACT:

SUBJECT:

□ For your information

S'Psr your request

O Advise status

n Please answer

□ Please handle

□ Note and return

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30323850

Superfund

08/10,94 10:24 2723 PEORIA DISPOSAL .@002Si 309 672

RCRA Disposal Facility

ff

In a rural setting near Peoria, TTlvnois, PDC operates a Part B Permitted RCRA disposal facility offering 1.8 million cubic yards of available capacity. With over 60 years ex­perience in the disposal business, the com­pany has developed a conservative manage­ment policy and strict acceptance criteria- It is a point of pride that PDC continues to develop new and innovative waste handlingmethods__ always with a concern forthe environment.

ns/10.'94 10:25 Ql 309 672 2728

Cell Construction

PEORIA DISPOSAL @1003

The PDC cell design consists of a secondary composite liner, leachate cohection/detection system, primary composite liner; and primary leachate collection system

Filter Fabric

HDPE Drainage Net Primary leachate Collection

The secondary liner is composed of a soil component and a flexible membrane compo­nent. The soil component consisting of three feet of recompacted clay with a maximum permeability of 1 x ID'7 cm/sec.. covers the trench bottom and sideslopes. Beneath this is a 50* thickness of insitu glacial till demon­strating a maximum permeability of 1 x 10'7. The synthetic liner component, constructed of 80 mfl high density polyethylene (HDPE), lies in direct contact with the soil component. The HDPE liner material has been extensively tested to assure compatibility with materials to be received in the cell.

The leachate collection/detection system is situated between the primary and secondary liners. It consists of an HDPE drain net blanketing the trench bottom and sideslopes. Collection trenches are spaced the length of the cell and are constructed to transmit leachate to the secondary collection sump. Layers of drain net axe placed in each trenchwhioh arliiftirp thp He-gign flow mairmnim

The dram net is made of an HDPE material, thoroughly tested for structural stability. It has demonstrated hydraulic conductivity of at least two orders of magnitude greater than the EPA minimum technology requirements of 1 x lO4 cm/sec., even when subjected to high

. confining pressures.

4‘ Slotted. HDPE Pipe Surrounded By Sand Bedding/ Filter Fabric

Bentonite Clay Mat

High Density Polyethylene SO Mil Thickness

HDPE Drainage Net Secondary Leachate [Collection

High Density Polyethylene 60 Mil Thickness

08/10/84 10:28 Ol 309 672 2726 PEORIA DISPOSAL @004

Collector trenches lead to thejseconriary sump which consists of a TniniTnrrm four foot diameter HDPE manhole. These man holes axe located at the low end of the trench and would receive gravity drainage from the detection system. The sump excavation is an integral part of the liner system jand functions

as a collection point for liquids transmitted to the secondary system. Additional riser sections are added as waste SI progresses to allow for removal of collected liquids.

.y'.v.ivv i-;

The primary liner, constructed of 80 mil HDPE matPTipl a synthetic clay component, and a 60 mil HDPE material, is installed directly over the leachate coHectirm /detection system. The 80 mil thickness has been selected over the 45 mil liner thickness suggested in the min murm technology requirements as an added safeguard.

Liner sections are fusion welded to form a continuous layer enri all welds are verified for integrity through field tensiometer and pressure testing.

The primary leachate collection, system, consists of granular bedding/drain material blanketing the trench bottom and an HDPE drain net completely covering the trench side slopes. Slotted HDPE leachate collection pipes within the granular drainage layer facilitate leachate drainage to the primary sump. Granular filter material covers the granular drain on the bottom of the trench, and non-woven polypropylene filter ■fabric over the drain net on the sideslopes inhibit waste fines from infiltrating the drainage system.

Collector pipes in the primary system are four inch diameter HDPE pipes, slotted along their entire length. Sloped to drain to the primary collection sump, the pipes radiate to dean-out manholes located at the upstream limits to facilitate cleaning from both ends.

08/10/84 10:27 SI 309 672 2728 PEORIA DISPOSAL ® 005

The primary leachate collection sump consists of a four foot diameter HDFE manhole situated at the low end of thejtrench adjacent to the detection system sumpl Collector pipes are sealed to the HDPE inside! and outside the sump wells. [

The primary leachate collection system is protected from inailxation of waste fines, which would reduce transmissivity, by a six inch rainfmnm thickness of soiL (filter) material above the drain net layer. The drain net along the sideslopes of the trench is: separated com direct contact with waste material by the polypropylene filter fabric.

All liners, drain nets and filter fabrics used on trench sideslopes are supported and held in place at the upper limits of the trench- This is accomplished by burying the end flaps of the bottom liner, bottom drain net, top liner, top drain net, and filter fabric in a trench measuring three feet deep by two feet wide.

These design specifications, along with a stringent construction quality control program, serve to support PDC's conservative approach to waste disposal and enhance the integrity of the Sim’s operations.

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lniiln Him

08/10/84 10:28 PEORIA DISPOSAL 1)0061 308 672 2726

Site Hydrogeology

The FDC facility is,underlain by a sequence of three major geologic units: j

Tllrnoian Drift: predominantly silty day till with, interbedded sand, gravel and silt;ShfiUjyvflle Outwash: predominantly sand with, some gravel and sihiy sand; and

Pennsylvanian: predominantly gray shaTpwith coal, limestone, and! sandstone.

dinoian DriftThe BJinoian Drift within the site bound­

aries extends from the surface to nsrimum depths of about 150 feet. Predominantly of sOty day tdl the upper 20 to 30 feet of the till is weathered. At greater depths] the tm usually

is dense, stiff and gray in color -with. Titrlfl evi­dence of alteration. The IGinoiau Drift contains sand lenses that typically range from less than 2 feet to about 10 feet thirV. When encoun­tered, they are excavated and backfilled with compacted clay/bentonite.

on samples of the till indicate permeabilities ranging from 6.6xl0~6to 1.3 jx 10-s cm/sec.

Disposal operations at the P DC fadliry are conducted in excavations into [the uppermost silty day till (rninoian Drift).

SheJbyville OutwashThe Shelbyville Outwash of dense, poorly

graded, brown sand with, occasional gravel or silt size particles, immediately unriefiipw the HEnoian Drift. The outwash is laterally contin- uous beneath the site-

The permeability of the sand is indicated by available laboratory penneameter tests to range from about 1.1 x 10 to 5.3 x 10-5 cm/sec.

Mean potentiometric elevations observed in. the site's monitor wells indicate groundwater flow under the site predominantly from the northwest to tha southeast.

BedrockBedrock at the site is the Pennsylvanian

Carbonade Formation, consisting of alternat­ing beds of shale, coal, sandstone and lime­stone with the shale predominating. Borings indicate that the predominant lithology immediately under the facility is shale.

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309 672 2726

Acceptance Criteria

i

PEORIA DISPOSAL

Future Plans

0007

Despite land, disposal restrictions imposed by the EPA and IEPA, FDC's acceptance criteria have not changed in several years.A conservative approach has Isept FDC ahead of agency rulings on the appropriateness of specific waste materials for landfill disposal A document describing FDC’s [acceptance

criteria in detail is available npon request-

in the future PDC plans to expand its capabilities beyond landfill disposal, remedia­tion and wastewater treatment. In prepara­tion. for upcoming restrictions, PDC is exploring new iocanerafion technologies. The company is also developing fixation and metal recovery processes for cadmium, chro­mium and lead. The scope of waste handling and disposal services available from PDC will be broader in the years to come.

Quality Control ofIncoming Waste

PDC maintains stringent gate control procedures to ensure that nonjconfrjrming waste cannot inadvertently be! accepted for disposal All bulk loads anci. 100% of all containers are sampled and tested, A chart detailing each, step in this procedure is available upon request.

FACILITIES:RCTRA Disposal Facility Wastewater Treatment Plant PDC Laboratories, Ins.ILD 000805812 XL #1438120003 4349 Southport ScL Peoria, IL 61615 309-676-4893

PDC Technical Services, Tnc. Corporate Office

PDC Technical Services, Tnc. P.O. Bax 9071 Peoria, IL 61612 309-688-0760

Transportation Services Hb 009848193Hi #00821113 2T. Swords Ave. Peoria. IL 61604 309-674-5176

iPDC Response, Lac.24 Hour Hotline 309-674-4238

REGIONAL OFFICES: Corporate Office 4700 W. Sterling Ave. Peoria. IL 61615 309-688-0760

12444 Powers Court Dr. Suite 300St. Louis, MO 63131 314-957-6334 or 6335

One Westbrook'— Corporate Center Suite 300Westchester. IL 60154 708-449-7730

1300 50th. St.Suite 106W.DesMbfues, IA. 50265 515-270-9646

2000 Town Center Suite 1900 Southfield, MI 48075 313-351-6226

Lexington Square Office Park 12700 SheibyvUle Rd.

Louisville. KY 40243 502-244-4150

7101 College BhroL Suite 415Overland Park, KS 66210 913-451-7606

Towers of Kenwood. 8044 Montgomery RdL Suite 700Cincinnati, OH 45236 513-792-2212Pcona 0*9C5al C&rwq

08/10/84 10:30 Ol 309 672 2726

State ofUlmois

ENVIRONMENTAL PROTECTION AGENCY

Mary A, Gade, Director

217/782-6761

May 16, 1994 ~

Peoria Disposal Company Attn: Ron HeIkPost Office Box 9071 Peoria, Illinois 61612-9071

PEORIA DISPOSAL @008

2200 ChcichM Road, Springfield, IL 61794-9276

Re; 1438120003 — Peoria County Peoria Disposal Company ILD000805812 Compliance File

Dear Mr, Helfc:

On April 28, 1994 your facility was inspected by John Tripses of the Illinois Environmental Protection Agency. The purpose of this inspection was to determine your facilityj's compliance with 35 Illinois Administrative Code, Part 703, Subpart B; Part 7Z2, Subparts A through G; Part 724, Subparts A through E, G, I, J, K, L, and N; Part 728, Subparts A, C, D, and E; and your facility's RCRA Part B Permit Sections I, II, III, IV, v, VII, VIII, and IX and Attachments A, B, C[ F, G, H, and I. At the time of the inspection, no apparent violations of the requirements addressed as part of the inspection were observed.

For your information a copy of the inspection report is enclosed. Should you have any'questions regarding the inspection, please contact John Tripses at 309/693-^62.

fc^n p

Brian Sf'flhite, Manager Compliance Unit Planning and Reporting Section Division of Land Pollution Control

B$H:JGT:PB:ct,695w,36

Printed ae Besrdtd Aver

Enclosure

08/10/84 10:30 ©1 309 672 2728 PEORIA DISPOSAL H009

RCRA Log 24 '

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

HAZARDOUS WASTE MANAGEMENT RCRA PART B PERMIT

IEPA #1438120003 — Peoria County USEPA ILD #00080581Z |Peoria Disposal CompanyPermit #B-24-M-19 iRCRA — Part B - Administrative Record

Issue Date: September 30, 1987 Effective Date: November 4, 1987 )Expiration Date: November 4, 1997Modification Effective Date: November 24, 19

Peoria Disposal Company 4700 North Sterling Avenue Peoria, Illinois 61615

A Part B permit is hereby granted pursuant to the Resource Conservation and Recovery Act, Illinois Environmental Protection Act, and Title 35 Illinois Administrative Code (ij.A.C.) parts 702, 703, 705, and 720 through 729 to the Peoria Disposal Company facility to construct/maintain and operate a waste management facility injvolved in the treatment, storage and disposal of hazardous waste. Peoria Disposal Company is located at 4349 Southport Road, Peoria, Illinois. j

This permit consists orf the conditions contained herein (including those in any attachments and appendices) and applicable regulations contained in the Illinois Environmental! Protection Act and Title 35 I.A.C. Parts 702, 703, 705 and 720 through 729 ini effect on the effective date of this permit. The Environmental Protection Act (111. Rev. Stat., Chapter 111 1/2, Section 1039) grants the Illinois Environmental Protection Agency the authority to impose conditions on permits which are issued. This Permit contains 76 pages including attachments |A through I.

If you have any questions regarding this final permit, please contact Mark A. Schollenberger, P.E. and/or Mark L. Crites, at 217/524-3300.

Qi vision of Land Poll lotion Control LWE:MC:sp/543Z/Z j

08/10/84 10:31 SI 309 672 2726 PEORIA DISPOSAL @010

Revised: October, 1993ILD000805812Page ii

I

GENERAL FACILITY DESCRIPTION

Peoria Disposal Company (PDC] is located at 4349 Southport Road, Peoria, Illinois. PDC is a mupti-faceted waste management company, including hauling, landfilling, liquid waste treatment, laboratory services, emergency response and remedial action.

Two double-lined surface impoundments will contain runoff from the active areas of the landfill. A third impoundment will collect runoff from areas that have intermediate! or final cover.

The RCRA facility, covering approximately ninety (90) acres, has seventy four acres in eight disposal units. Two units have compacted soil liners, one unit has compacted soil under high-density polyethylene (HOPE) liner and a leachate collection system above both liners. Five new units will have a double HDPE liner with leachate collection and leak detection system, all over a compacted soil liner. j

The groundwater monitoring system includes twenty four wells for sampling and analyses (and two for groundwater level indicators only). As Landfill Area C progresses, additional[wells will be installed in the She!byvilie sand and in shallow flow zones where they exist, for a total of 8-11 additional wells yet to be installed. Wells will be sampled quarterly during the active life including closure and post-closure periods. Groundwater samples are analyzed for parameters based on waste characteristics and groundwater characteristics.

After closure of each landfill cell, it must be periodically inspected and maintained. The thirty year post-closure period begins following closure of the last landfill uniti Groundwater samples must also be analyzed quarterly during the post-closure period.

I'A wastewater treatment[system for hazardous liquids will be built at the facility. Four tanks will be constructed for storage of incoming hazardous liquids and leachate (i[rom the PDC landfill). Each tank Will contain a maximum of 20,000 gallons and will have secondary containment to collect any leaks cr spills from trie tank system.

A waste stabilization facility is present to solidify wastes or chemically bind metals present to minimize the hazardous characteristics of the wastes. The stabilization facility has a secondary containment system to collect leaks or spills, and a leak detection system between the concrete foundation and an HDPE liner. i

Two twenty-five cubic yard bulk transport trailers will be used to store dry wastes so they may be disposed with wastes that have higher moisture content. The trailers will be located in the active disposal cell.

08/10/84 10:31 ©1 309 672 2726 PEORIA DISPOSAL @1011

/

Revised: October, 1993110000805812Page iii

A solids storage building is proposed to be constructed consisting of a container storage area, nine hazardous waste storage tanks and other appurtenances/ancillarpr equipment (backboe, ...) necessary to operate the facility safely and in an environmental manner. The solids storage buildinq has a secondary containment system to collect spills and leaks and a leak detection system between the concrete foundation and the HOPE liner.

Two proposed storage silos will be used to store dry, powdery wastes for eventual treatment in the waste stabilization facility. These units will have a concrete vault as a secondary containment system.

The section of the RCRA Permit entitled the “List of Required Plans Contained in the Approved Permit] Application" identifies the location of various documents in the Application. Subsequent portions contain {1} sections for each RCRA permitted unjit and operation, which are tailored to the facility,(2) standard conditions that apply to all RCRA permitted facilities, and (3) the facility reporting! and notification requirements. The inspection schedule, lists of washes managed at each unit and a site plan are provided as attachments to the permit document.

The permit for Peoria Disposal Company contains all of the standard conditions required by 35 IAC, Parts 702 and 703; the applicable general facility conditions of 35 IAC, Part 724; and the applicable conditions of 35 IAC, Part 724 for storage of hazardous waste in containers, tanks, piles, and surface impoundments, for treatment of hazardous waste in piles and tanks, and for disposal of hazardous waste in landfill units. Peoria Disposal Company is an existing facility and has been operating under a RCRA Permit since November 4,

08/10/94 10:32 SI 309 672 .2726 PEORIA DISPOSAL @012

Revised: October, 1993ILD00080581ZPage V-l

Section V LANDFILLS

A. SUMMARY

Peoria Disposal Company operates a ninety (90) acre facility, seventy-four (74) of which are approved for disposal units. The total waste capacity is approximately 1,847,200 cubic yards. Industries served by the site include eartbmovirig and agricultural equipment manufacturers, chemical and steel companies, and breweries* Some wastes are to be treated at the Stabilization Unit at the facility prior to disposal in a landfill cell*

The landfill is to be operated so as one landfill unit is nearing final capacity and closure, the next unit is.prepared for disposal activity. The final landfill unit is scheduled to close in the year 2005.

This section presents permit conditions for the landfill according to the regulatory requirements of 35 IAC 724 Subparts N (Landfills) and G (Closure).

B. HASTE IDENTIFICATION

1. The landfill! disposal units are, or are to be, located as shown in Attachment F to this permit.

2. The Permittee may dispose the following wastes in landfill cells, subject to the terms of this permit:

Landfill Cell Designation

Barrel Trench Area

Section A Section B Trench C-l Trench C-2 Trench C-3 Trench C-4 Trench C-5

3. The Permittee

TotalCapacity fc.v.)

35,000

6,500190,000303.700252.700346.700 409,500 303,100

Surface Area Dimensions of Landfill Cell

(Acres)

14

8107.96.87.7

11.87.9

Descriptionof

HazardousWaste

See Attachment C for Waste List and Hazardous Waste Nos.

andNon-hazardous waste approved by IEPA special waste stream permit

Jis prohibited from disposing any waste in the permitted

units not included in Condition B. 2. of this Section.

03/10/94 10:33 ®1 309 672 2728 PEORIA DISPOSAL 2)013

Revised: October, 1993ILD0008Q5812Page VI-1

Section VI DETECTION MONITORING

A. SUMMARY

The Peoria Disposal Facility has nineteen (19) wells to monitor groundwater in the Shelbyville Sand. Three additional wells will be installed as disposal progresses. The average depth to groundwater in the deep wells is 145 feet.

B. WELL LOCATION AND CONSTRUCTTAN

The Permittee shall install and maintain a groundwater monitoring system at the point of compliance as specified below:

1. The Permittee shall install and maintain groundwater monitoring wells and piezometers at the locations specified on the map presented injthe Approved Permit Application and in conformance with

' the following list:■i

WellNo. No te Area

WellDepthift-1

Well Depth Elevation fft. MSL)

Well Screen Interval (ft. MSL1

R122 BT 146.0 457.6 458.1-468.1

G128 6 BT 130.4 461.0 461.5-471.5

R128 5 BT — -- —

* R132 BT 127.0 462.7 463.2-473.2

* R133 ST 111.0 468.3 468^8-478.8

* R134 BT 123.0 465.5 ■ 466.0-476.0

£120 1 A 184.0 428.9 429.4-449.4

RI21 A 145.8 459.7 460.2-470.2

£142 4 A — — —

£140 WT 201.4 • 455.6 456.1-466.1

08/10/94 10:33 Ol 309 672 2728 PEORIA DISPOSAL 11014

Revised: October, 1993ILD000805812Page VI-2

Well Well Depth Well ScreenWell Depth Elevation IntervalNo. Nate Area (ft-1 fft. HSU fft. MSL1

6119 1 B‘ 193.6 423.8 424-444 *

R126 i B 153.5 457.7 458.2-468.2

G139 B 173.5 456.1 456.6-466.6

P116 2,3 46.0 463.5 470.0-475.0

R125 B 157.0 457.7' 458.2-468.2

R113 1 C 194.0 416.0 416.5-436.5

P127 1,2 C 93.0 459.4 461.7-471.7

RI29 C 169.0 458.8 459.3-469.3

R130 C 162.0 460.3 460.8-470.8

R131 C 154.0 460.0 460.5-470.5

G135 4 c — —

G136 c 123.0 449.1 449.6-459.6

G137 c 141.0 447.4 447.9-457.9

R138 c 163.5 449.4 449.9-459.9

G141 4 c — — —

*Upgradient well (all others downgradient)

Well Designations

G — Groundwater monitoring well P — PiezometerjR — Replacement groundwater monitoring well

PEORIA DISPOSAL @01508/10/94 10:33 ©1 309 672 2726

Revised: October, 1993ILD000805812Page VI-3

tfotesI2,3456 7

PVC well, twenty foot screen Piezometer for water level only PVC well!Deep well, not yet installed Shallow well, not yet installed Well to be replaced Wells ijo be installed

Area monitored by designated well:BTT — Barrel Trench A — Section A B — Section B C — Ar;ea CWT — Wastewater Treatment Unit (Non-hazardous)

2.

3.

The Permittee shall construct and maintain the monitoring wells and piezometers [identified in Condition B.l of this Section in accordance wpth the detailed plans and specifications presented in the Approved! Permit Application, unless otherwise approved in writing by the Agency's DLPC. Wells to be installed shall be installed and developed at least ninety (90) days prior to placement of waste in the respective cell

Replacement wells shall be constructed in accordance with the detailed plans and specifications presented in the Approved Permit Application,! or in accordance with Agency guidelines current at the time of replacement if different, unless otherwise approved in writing by the Agency's DLPC.

All wells dejl-eted from the monitoring program and no longer used by the Permittee for his own purposes, shall be plugged and abandoned in accordance with the plans in the Approved Permit Application. Well plugging and abandonment methods and certification shall be submitted t6| the following address within sixty (60) days after the wells are removed from the monitoring program. Any well deleted from the monitoring program and used by the Permittee shall be maintained in accordance with DLPC criteria.

Illinois Environmental Protection Agency Permit Section Groundwater UnitDivision of land Pollution Control — #24 2200 Churchill Road Post Office Box 19276Springfield, Illinois 62794-9276

08/10/94 10:34 ©1 309 672 2726 PEORIA DISPOSAL @010

Revised: October, 1993ILD000805812Page VI-4

4. Boring logs, construction diagrams, and data sheets from development of new or replacement wells shall be submitted within sixty (60) days of completion of well installation.

5. The screened interval of the replacement well R128 shall behydraulically equivalent to that of the original well, G128. The original well shall be maintained until such time that R128 can be installed and developed. Once the water quality of both wells have been compared and found to yield equivalent data, then G128 can be decommissioned in accordance with Agency standards.

C. MONITORING PARAMETERSl

1. The Permittee shall monitor the wells described in B.l above for the following parameters:

Parameter

la. Heavy metals I Barium, Ba (diss) Cadmium, Cd (!diss) Chromium (disjs)Iron, Fe (disls)Lead, Pb (dis’s) Manganese, Mn| (diss) Nickel, Ni (dtiss)Zinc, Zn (diss)

b. Volatile Compounds Vinyl chloride Chloroethane | Methylene chloride Trichlorofl uoromethane1.1- dichloroethanet-1,2-dichioroethene1.1.1- trichloroethaneTetrachloroet leneChlorobenzene

c. Semi-Volatile Compoundphenol

Parameter

d. Water Oualitv ParametersCalcium, CaChloride, Cl dTss)Cyanide, CN (1total)

STORET NO. CAS NO. PQL

01005 7440-39-301025 7440-43-9 501030 7440-47-3 1001046 7439-89-6 10001049 7439-92-1 501056 7439-96-501065 7440-02-0 4001090 7440-66-6 20

39175 75-01-4 1034311 75-00-3 1034423 75-09-2 534488 75-69-4 1034496 75-35-3 534531 156-60-5 534506 71-55-6 534475 127-18-4 534301 108-90-7 5

32730 108-95-2 5

STORET NO. CAS NO. PQLi

00915 .0094100720

08/10/84 10:34 SI 309 672 2728 PEORIA DISPOSAL @1017

Revised: October, 1993ILD00080581ZPage VI-5

Parameter STORFT HO. CAS NO. PQLi

pH-(field)Sodium, NaSpecific Conductance,

SC (field)Sulfate, SO4 (diss) Total Organic

Carbon, TOC Total Organic

Halogen, TOX

0040000930

0009400946

00680

78115

1Practical Quantitation Limit in ppb.

phenols, Specific Organic Halogen,

NOTE: Values for all constituents listed above, except cyanide, pH,Conductance, temperature, Total Organic Carbon, Total and organics, are to be determined from a sample that

has been field filtered through a 0.45 micron filter membrane.

2. For those parameters in Condition C.l of this Section for which no background vajlues are established at the time the permit is issued, the Permitee shall establish background values in accordance with the following procedures.

a. Background groundwater quality for a monitoring parameter or constituent shall be based on data from quarterly sampling of the wells upgradient from the waste management unit for one (1) year.

b. In developing the data base used to determine a background value for each[parameter or constituent, the Permittee shall take a minimum of two samples from each upgradient well each time the monitoring system is sampled. An equal number of samples shall be takenjfrom each upgradient well to ensure equal weightings in statistics.

c. For those monitoring parameters or constituents not detected above the practical quantitation limit during background gathering, the practical quantitation limit in Condition C.l of this Section shall be the established background value.

D. SAMPLING AND ANALYTICAL PROCEDURES

The Permittee shall use the following techniques and procedures-when obtaining and analyzing samples from the groundwater monitoring wells described in Condition B of this Section.

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